Summary
referencing the "'high burden of showing that Rule 11 sanctions are warranted'"
Summary of this case from Holland v. City of GaryOpinion
Civil Action No. 08-C-400
12-02-2011
PACKAGING SUPPLIES, INC., Plaintiff, v. HARLEY-DAVIDSON, INC.; and HARLEY- DAVIDSON MOTOR COMPANY, INC., Defendants HARLEY-DAVIDSON, INC.; HARLEY- DAVIDSON MOTOR COMPANY, INC.; and H-D MICHIGAN, LLC, Counterclaim Plaintiffs, v. PACKAGING SUPPLIES, INC., Counterclaim Defendant.
By: Thomas M. Williams WINSTON & STRAWN LLP BAKER BOTTS LLP 1299 Pennsylvania Ave., N.W. Washington, DC 20004 James G. Kress Barbara O. Bruckmann Charles M. Malaise Counsel for Hurley-Davidson, Inc., Hurley-Davidson Motor Company, Inc., andH-D Michigan, LLC By: Alan F. Block BLOCK & LANDSMAN Counsel for Packaging Supplies, Inc.
Hon. , Jr.
STIPULATED MOTION FOR ENTRY OF CONSENT JUDGMENT
Pursuant to the Court's Minute Entry (Dckt. #98), dated November 22, 2011, the Parties respectfully submit this Stipulated Motion for Entry of a Consent Judgment. In support of this Stipulated Motion, the Parties state:
1. The proposed Consent Judgment, attached hereto, was the subject of arms-length negotiation and agreement of the Parties and their counsel of record as an integral part of a comprehensive, confidential Settlement Agreement.
2. The terms of the proposed Consent Judgment are consistent with the issues adjudicated and found by this Court in its Memorandum Opinion and Order, dated May 12, 2011, and with the requirements of Federal Rule of Civil Procedure 65.
3. The Parties' Settlement Agreement and proposed Consent Judgment fully and finally resolves all issues in this litigation. Entry of the proposed Consent Judgment should permit the Court to enter a final judgment in this matter.
Wherefore, the parties respectfully request the Court to enter the proposed Consent Judgment attached hereto as Exhibit 1.
By: Thomas M. Williams
WINSTON & STRAWN LLP
BAKER BOTTS LLP
1299 Pennsylvania Ave., N.W.
Washington, DC 20004
James G. Kress
Barbara O. Bruckmann
Charles M. Malaise
Counsel for Hurley-Davidson, Inc., Hurley-Davidson
Motor Company, Inc., andH-D Michigan, LLC
By: Alan F. Block
BLOCK & LANDSMAN
Counsel for Packaging Supplies, Inc.
CERTIFICATE OF SERVICE
The undersigned counsel hereby certifies that on December 2, 2011, a true and correct copy of STIPULATED MOTION FOR ENTRY OF CONSENT JUDGMENT was filed with the Court's CM/ECF system, which will send electronic notice to all attorneys of record.
Thomas M. Williams
CHI:2601047.1